Statement Regarding Allegations on the CBCG's Conduct in the Enforced Collection Procedure Against the Municipality of Budva Accounts

06/05/2026

Following statements in the public concerning CBCG's Conduct in the Enforced Collection Procedure Against the Municipality of Budva Accounts, particularly claims that the CBCG “allowed an account freeze without prior notice” and insinuations of possible political influence on its actions, and for the purpose of ensuring accurate public information, we hereby state the following:

The CBCG conducts enforced collection against funds held in the accounts of legal entities and entrepreneurs in accordance with the law governing enforcement and security of claims, and on the basis of enforcement decisions issued by the competent authorities.

In this regard, the CBCG does not initiate enforced collection proceedings, does not determine the existence of debt, and does not decide on the rights and obligations of the parties involved. Its role in this process is clearly defined by law and is limited to executing formally valid orders issued by competent authorities. Upon receipt of such an order, the CBCG is legally obliged to act without delay, i.e. to carry out collection from the accounts of the enforcement debtor where funds are available, in favour of the enforcement creditor’s account, in accordance with the order and time of receipt of the instructions.

In the specific case, the CBCG received an enforced collection decision from the competent public bailiff on 29 April this year, which was executed in line with the above-described legal procedure.

We also emphasise that, within enforced collection proceedings, the CBCG is not authorised to notify the enforcement debtor in advance of the receipt of an enforcement order. Namely, the law stipulates that from the moment an order to freeze the debtor’s account is received until the freeze is implemented, as well as throughout the duration of the freeze, the funds in that account may not be used for other payments.

It should be noted that the CBCG verifies only the formal validity of the submitted enforcement orders, without authority to review the correctness of enforceable or authentic documents, nor to assess the merits of the claim. Responsibility for the legality and content of the acts on the basis of which enforcement is carried out lies with the issuing authority, in this case the public bailiff.

In light of the above, claims and insinuations of political influence on the conduct of the CBCG are entirely unfounded. The CBCG performs its duties professionally, impartially and independently, strictly in accordance with the Constitution, the law and the principle of institutional independence.

Andrija Jovović

Director of the Payment System Department